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Disclaimers & Escalation Gates

Circular 230, UPL, draft-status, and the escalation gates required before any cohort-facing implementation.

Disclaimers

Every page in the tax-architecture module is research material. Nothing here is legal or tax advice and nothing here may be relied on as such. The HigherSelf Network has not engaged any of the readers of this module as their lawyer, accountant, ERISA counsel, or fiduciary. No attorney-client relationship is created by reading.

Circular 230 notice#

Treasury Department Circular 230 (31 C.F.R. Part 10) governs practice before the IRS. Anything that could be construed as written tax advice is general research only, is not intended to be used and cannot be used to avoid tax penalties, and is not written to support the promotion or marketing of any matters addressed.

Unauthorized practice of law#

Tax law involves both federal and state authority. Where state law applies (entity formation, state income tax, sales tax, payroll, etc.), licensed counsel in the relevant jurisdiction is required. State unauthorized-practice-of-law statutes constrain who may give specific advice on filings, contracts, and dispute resolution.

Draft status#

All cohort-facing artifacts in this module ship with a DRAFT — pending professional review banner until the following gates clear:

| Gate | Purpose | Reviewer | |---|---|---| | Lumina UPL / tone review | Catches language that crosses into specific advice; enforces consistent voice | Lumina | | Outside CPA review | Validates tax-substance positions, computations, and citations | Engaged CPA | | ERISA-counsel review | Reviews any retirement-plan, ROBS, or plan-loan content | Engaged ERISA attorney | | Grace Fields authorization | Final cross-entity gate before publication | Grace Fields | | Cohort consent | Required for any externalized version of a worked example using real cohort facts or names | Written consent on file |

Until each gate clears, calculators in this module ship behind a "not advice" interstitial that the user must click through, and worked examples use anonymized labeling.

Sunset and verification warnings#

Several core mechanisms in this module are subject to legislative sunset or annual inflation adjustment:

  • § 199A QBI deduction — currently scheduled to sunset after 2025 unless Congress extends. Verify current law before any 2026 communication.
  • 2026 retirement plan limits — sourced from IRS Notice 2025-67. Verify against the most recent IRS publication for any actual filing.
  • HSA contribution limits — verify in the IRS Rev. Proc. that publishes annual HSA inflation adjustments.
  • Estate and gift exclusions — sunset to lower amounts is scheduled; verify current law.

Preparer penalty disclosure#

Anyone advising the cohort on tax positions could be a "tax return preparer" within IRC § 7701(a)(36) and Treas. Reg. § 301.7701-15. HSN agents and contractors may not give cohort members specific tax advice that will be reflected on returns without (a) appropriate licensure or (b) clear disclaimer that the advice is general and the cohort member must engage their own CPA.

Cohort facts are confidential. Real names, financial details, and identifying details may not be used in any external-facing artifact without written consent on file. The default framing across this module is anonymized ("Cohort Bakery, LLC (worked example)") until consent confirms a specific cohort member's facts may be used.

Reporting concerns#

If a cohort member or HSN insider arrives with a scheme that resembles any pattern listed in research/do-not-do-this, escalate immediately to Grace Fields and Lumina. Document the conversation. Mark "research only — not advice." Refer the cohort member to a licensed CPA.